A new wave of disruption is hitting the short-term rental market following the mass dispatch of notifications by Greece’s Independent Authority for Public Revenue (AADE) to property owners operating through platforms such as Airbnb and Booking.com. Since the beginning of the week, hundreds of taxpayers have been receiving electronic notices regarding potential discrepancies and undeclared income for the tax years 2020, 2021, 2022 and 2023, after cross-checks based on data submitted by the platforms themselves to the tax authorities.
The process had effectively been foreshadowed during the recent Short Stay Conference, where market participants warned of stricter controls in the short-term rental sector. However, the scale of the notifications, combined with cases already being disputed by taxpayers, is causing significant unrest in the market.
Why audits start from 2020
AADE has launched audits beginning with the 2020 tax year, as this period is approaching the expiration of the five-year statute of limitations for unassessed tax liabilities. In this context, extensive cross-checks are being conducted between declared income, entries in the Short-Term Rental Registry, and data submitted by the platforms.
As a result, thousands of property owners have received notices effectively requiring them to prove that the amounts reported on the platforms match those declared to the tax authorities. Many owners immediately logged into platform dashboards to download invoices, payment histories and booking data in an effort to identify the discrepancies flagged by AADE.
The most common reporting mistake
According to market insiders, the most frequent error relates to how income from short-term rentals was reported. In many cases, property owners declared the net amount credited to their bank accounts—that is, the amount after platform commissions, payment processing fees and other charges were deducted.
However, for tax purposes, the taxable income is defined as the gross amount paid by the guest before any deductions. This discrepancy is now forcing many owners to submit amended tax returns, face a €100 penalty, pay additional tax, and incur extra accounting costs to correct their filings.
A typical example involves a property owner operating via Booking.com, who received a notice for undeclared income of €8,143 for 2022. After downloading platform invoices, the owner discovered that the total booking value, including fees and commissions, actually reached €8,495. The owner admitted that at the time they declared only the amount received in their bank account, unaware that the gross booking value should have been reported.
The “pandemic trap” and deferred payments
Cases related to 2020—the year of the pandemic—are proving particularly complex, as most bookings were cancelled and the short-term rental market was effectively frozen for months.
In several instances, property owners had opted to receive payouts only after reaching a minimum threshold. As a result, payments relating to bookings from different years were grouped together and paid out at a later date.
One owner reports having just €300 in bookings in 2020 due to widespread cancellations. However, because they had set a €2,000 payout threshold on Airbnb, the platform transferred €2,000 in 2020, including balances from 2019 bookings. Despite this, AADE recorded the full amount as 2020 income and is now requesting justification for “undeclared income” of €1,700.
The owner describes the situation as “highly unprofessional,” arguing that the cross-checks rely solely on payment dates rather than the actual period when bookings occurred.
Cancellations recorded as double income
Another major issue concerns booking cancellations and refunds. Property owners report cases where guests cancelled due to flight changes or other issues, and partial refunds were agreed privately.
When the property was rebooked for the same dates, the original guest was compensated accordingly. However, the platform appears to have recorded both the original and the new booking as completed transactions. As a result, AADE’s cross-checks show inflated income amounts which, according to owners, were never actually received.
Cases where taxpayers declared higher amounts
Among discussions in online owner communities, there are also cases where taxpayers claim to have declared higher amounts than those recorded by AADE.
One property owner reports receiving a notice for €4,275 in undeclared income from Booking and Airbnb, despite declaring €4,496 via the tax system. The discrepancy is believed to be linked to a cancelled booking for which payment was eventually received and properly declared.
Confusion over registry numbers after inheritance cases
Problems have also emerged in cases involving changes in property management or the death of an owner. In one reported case, a property was initially owned and managed by a mother through Booking.com. After her death in 2022, the original registry entry was terminated, future bookings were cancelled, and a new registry number was issued under a different manager.
Despite tax returns being properly submitted for both periods, AADE appears to have combined income from both registry entries using the same property identification number (ATAK).
In the coming period, it remains to be seen whether AADE will assess separately cases involving timing differences, cancellations or technical platform issues. Until then, the short-term rental market is closely monitoring a process that has already caused significant disruption for thousands of property owners.
